RAY v. C.I.R.

No. 20-60004.

13 F.4th 467 (2021)

Ames D. RAY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

FILED September 14, 2021.


Attorney(s) appearing for the Case

Susan S. Vance , Susan Vance Law, P.L.L.C., Canyon Lake, TX, for Petitioner—Appellant.

Rachel Ida Wollitzer, Esq. , Jacob Earl Christensen , Michael J. Haungs, Esq. , Supervisory Attorney, David A. Hubbert , U.S. Department of Justice, Tax Division, Appellate Section, William M. Paul , Internal Revenue Service, Washington, DC, for Respondent—Appellee.

Before Dennis, Higginson, and Willett, Circuit Judges.


Appellant Ames D. Ray claimed a deduction for certain legal expenses on his 2014 federal income tax return. The Internal Revenue Service disallowed this deduction and issued a notice of deficiency to Ray. The IRS imposed an accuracy-related penalty in addition to the deficiency amount. Ray filed a petition with...

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